Massachusetts Court Discusses Choice of Laws in Workers’ Compensation Matters

Workers’ compensation matters are often complicated and involve multiple insurers and parties from numerous states. As such, there are sometimes disputes as to which state’s laws apply. Recently, a Massachusetts court issued an opinion setting forth a choice of laws analysis in a workers’ compensation matter in which the parties disputed whether a subrogation action was time-barred. If you suffered harm while working, you could be owed benefits, and it is in your best interest to confer with a Massachusetts workers’ compensation attorney regarding your options.

The Facts of the Case

It is reported that this matter arose out of an incident in which the claimant suffered serious harm while working at a construction site. The claimant’s employer and its insurer subsequently filed a subrogation claim against multiple third-party Connecticut-based construction companies to recover benefits paid to the claimant on the employer’s behalf. In part, the employer and insurer alleged that the companies provided a defective fall arrest system for the employee that failed, causing the employee to fall and sustain serious injuries. The defendants moved for dismissal on the pleadings on the grounds that the action was barred by the statute of limitations under Connecticut law. The trial court granted the motion, and the employer and insurer appealed.

Choice of Laws Analysis in Massachusetts Courts

On appeal, one of the primary points of contention was whether Connecticut’s or Massachusetts’ statute of limitations applied. The court explained that in terms of choice of law with regard to statutes of limitations, its rule was that the law of the State where the action was filed generally applies with regards to whether a claim is timely unless maintaining the claim would serve no substantial interest of the forum, and the claim would be barred under the statute of limitations of a state having a more significant relationship to the parties and the harm suffered.

In the subject case, the court found that Massachusetts had a significant interest in the matter, regardless of whether the injured worker and third-party construction companies were residents of Connecticut and the workers’ compensation benefits were paid out under Connecticut law. Specifically, the Commonwealth had an interest in allowing injured parties to seek redress for their losses. Thus, the court found that Massachusetts’ three-year statute of limitations applied, and therefore, the claims were not time-barred. As such, the court reversed the trial court ruling and reinstituted the employer’s and insurer’s claims.

Meet with a Knowledgeable Massachusetts Workers’ Compensation Lawyer

Employers have an obligation to provide employees who are injured at work with workers’ compensation benefits, and it is smart for anyone who suffers a workplace injury to meet with an attorney. James K. Meehan of the Law Office of James K. Meehan is a knowledgeable workers’ compensation lawyer, and if you were hurt at work, he can assess your harm and help you seek the full amount of benefits recoverable. You can contact him via the form online or by calling 508-822-6600 to set up a conference.